How do you convince your board that ethics and compliance pay? This is a fundamental issue that all ethics and compliance professionals need to address and communicate to the board and to your senior management. Ethics and compliance are not a cost center. The research is overwhelming that ethics and compliance provide greater financial stability and sustainability for every organization. It’s called the ethics premium,...
The U.S. State Department’s Directorate of Defense Trade Controls (DDTC) recently imposed a $36 million penalty on General Electric (GE) for widespread violations of the International Traffic in Arms Regulations (ITAR). The enforcement action highlights persistent compliance failures across multiple dimensions — including technical data exports, licensing errors, and internal control breakdowns — and serves as a critical reminder of the risks companies face in...
As companies accelerate adoption of artificial intelligence tools across business functions, one reality is becoming increasingly clear: AI risk is not theoretical—it is operational, immediate, and enterprise-wide. From generative AI tools used in marketing and legal functions to machine learning embedded in products and decision-making systems, organizations face a rapidly evolving risk landscape that cuts across privacy, cybersecurity, intellectual property, employment law, and regulatory compliance....
Here are 3 more reasons you may think twice about letting ChatGPT run your compliance program. First, content monitoring. The content that you generate through Chat GPT or any AI service can raise real risks with regard to improper intellectual property, data privacy risks where you name certain individuals or name certain identifiers, and most importantly, remember your third-party risks. When it comes to AI...
The Treasury Department, through a coordinated rulemaking effort involving OFAC and FinCEN, has taken a significant step toward formalizing anti-money laundering and sanctions compliance expectations for a rapidly evolving segment of the financial services industry—permitted payment stablecoin issuers. The recently issued Notice of Proposed Rulemaking reflects a deliberate attempt to bring these entities squarely within the ambit of the Bank Secrecy Act framework, while at...
The Department of Justice’s recent declination in the Balt Medical matter provides another important data point in understanding how DOJ is applying its updated Corporate Enforcement and Voluntary Self-Disclosure Policy in practice. While declinations are always fact-specific, this letter offers a textbook example of how a company can navigate a significant FCPA issue and still avoid criminal prosecution. The declination letter, issued to Balt SAS,...
On April 7, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) unveiled a sweeping proposed rule aimed at modernizing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations under the Bank Secrecy Act (BSA). The proposal, developed in coordination with federal banking regulators, reflects a significant evolution in how regulators evaluate compliance programs, enforce obligations, and encourage innovation. At...
Artificial intelligence is rapidly transforming business operations—but it is also introducing a new generation of legal, ethical, and compliance risks. In this episode, we explore how AI risk is accelerating across organizations, from data leakage and bias to over-reliance on flawed outputs and hidden third-party exposure. Drawing on real enforcement trends and practical examples, we explain why AI risk is fundamentally a human and governance...
Are you actually thinking of turning over your compliance program to ChatGPT? If so, you need to listen to this. AI has to be implemented in a methodical way, a step-by-step program. So let’s talk about those steps. First, you need a governance structure, meaning you have to have an organization responsible across the entire organization for all your uses of AI. Second, like every...
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an Order resolving an administrative enforcement action involving Coastal PVA Technology, Inc., a California-based manufacturer of polyvinyl alcohol (“PVA”) brushes used in semiconductor manufacturing processes. The action arises under the Export Administration Regulations (“EAR”) and follows the issuance of a Proposed Charging Letter alleging multiple violations stemming from exports to restricted parties in...
